Dr. Belford's official . pdf submission: Click here

To: Ms. Jenelle Partap May 20, 2020

Corporate Secetary

Environmental Management Authority #8 Elizabeth Street

St. Clair, Port of Spain

Response To: Toco Port EIA (CEC5345_2017 Toco Port Project EIA)

I am currently an Associate Professor of Biology at Martin Methodist College, Pulaski, Tennessee, United States. I have been conducting research on the reefs at Toco since 2005 with Dr. Dawn A.T. Phillip, former lecturer at The University of the West Indies (St. Augustine). Since the inception of our coral reef monitoring, our objective is to study, present, and publish data highlighting the distribution, coverage, and identification of marine biota along the northeastern coast of Toco: from Grande L’Anse to Galera Point. Genetic analysis of marine biota has now been added to our objective, as genetic tools now further our knowledge of the intricate features of various benthic organisms.

Photographs of marine organisms have been added to the Digital Public Library of America (DPLA), as a resource with full public access that highlights the unique marine biota of Toco reefs. Please feel free to contact me for further information.

Regards

Stanton Belford

From: Stanton Belford, Ph.D. Associate Professor, Biology Martin Methodist College

433 West Madison Street Pulaski, TN. 38478

Office #: 931-424-4621

email: sbelford@martinmethodist.edu

433 W Madison St, Pulaski, TN 38478-2799 ·

1-800-467-1273 Fax (931) 363-9818 www.martinmethodist.edu

ES.1 Executive Summary

The multipurpose port will be built at Grande L’Anse Bay, Toco (“the Project”), as described (ES.1) is the specific area between 10º50.107´N, 60º56.772´W and 10º50.266´N, 60º56.674´W, which since 2005 to 2020 has been a main site (Site 1) for coral reef monitoring. The proposed port project, which covers 19.9 Ha (ES.

1.1.) includes the aforementioned specific site (Site 1) which has been monitored by faculty and students of The University of the West Indies (UWI), St. Augustine and Martin Methodist College (MMC), Pulaski, Tennessee, U.S.A. Other students from various academic levels in Trinidad have also assisted with data collection (ecological and genetic data collection). From these activities, published scientific literature, and online documentation of marine organisms have added contributions to continue coral reef monitoring in this unique region (see references).

Although “the physical, environmental, and social baselines for this EIA were compiled using existing information from published literature, and from baseline studies conducted by ERM and NIDCO subcontractors (ES. 1.2.2.),” there is no indication that these published scientific literature from coral reef monitoring

2005-2020 made any difference in the decision to eliminate the proposed port from consequences of 100% destruction of the reef habitat at Grande L’Anse.

The term “benthic communities” (ES. 1.5.1) is not clearly defined. Additionally, the Fisheries Act, Chapter 67.51 which defines the term fish to include oysters, shrimps, turtles, and corals (2.3.1), summary of initial and residual impacts includes “fishes” which is defined as numerous fish species, and used relative noise associated with dredging, pile driving, vessels (Table ES. 1. 6-1). In essence, there is no definition for “benthic communities.”

Coral reef benthic communities have many features and characteristics that make them a dynamically unique habitat. Essentially the macrobiota highlighted in available studies for Grande L’Anse provides ample proof that it is paramount to save the reef rather than search for loopholes to proceed, or mislead using sources that are not intended to support this particular venture. My focus is specifically geared towards the marine environment, as that is what my specialty is in. My focus is on the marine environment at Toco, as this has been my research site for the last 20 years, while working alongside researchers with credentials and well- respected by their peers. I also have had a long list of student and citizen volunteers both locally and internationally. I have never doubted Dr. Margaret

Mead’s quote, “never doubt that a small group of thoughtful, committed, citizens can change the world.”

The EIA document presents pages documenting the description of a project that is NOT in the interest of the environment, specifically the marine environment.

Statements made throughout various parts of the EIA document are generalized, and not supported. Additionally, the disparity between communication between the Minister of Works and Transportation, NIDCO and ERM personnel is misleading and confusing. Since 2019, and the patchy arrival of the Application for Certificate of Environmental Clearance (CEC5345/2017) together with numerous newspaper articles and video interviews concerning the Toco port development, the coral reefs at Grande L’Anse have been placed on notice. As highlighted by articles in the Express Newspapers by Mark Meredith, together with responses/interviews/blogs in the Guardian and Newsday (Dr. Anjani Ganese) newspapers, the reefs are important, but will be destroyed, yet the Minister of Works and Transportation has said that it will not, and now the EIA states that it will be. So, after reviewing the documentation by the EIA, my decision is based on the destruction of the marine environment that will occur if this project proceeds, therefore I feel that the Toco Port should NOT proceed.

I have highlighted areas in the EIA documentation that supports my concerns, as well as the decision to not proceed with the Toco port.

EIA 3 As in any scientific research, the basis of the research focuses on a research question, and guided by an objective. As stated in the project description (EIA Chapter 3: Project Description), the justification of building the port outlines (a) linking the northeastern coast of Trinidad and Tobago, which would increase tourism and connection between islands: the term tourism has many facets, therefore I highlight visitor tourism, which means persons from local or abroad visiting a site for pleasure. The site of the project (Figure 3.1-1) will eliminate one site frequently visited by international students whom study coral reefs.

Additionally, student visits from The University of the West Indies (St. Augustine) to study the reefs will decrease invaluable financial input ($U.S. and $T.T.) to local guest houses and food vendors in the Toco vicinity.

EIA 3.3. The EIA’s statement, “the reef is very sparsely populated with corals and is effectively devoid of resident marine life (EIA 3.3)” is contrary to published research articles. For instance, the number of species recorded at Grande L’Anse and Salybia Reefs were similar, with a greater species richness of many other

marine invertebrates, such as echinoderms and poriferans reported at Grande L’Anse (see Belford & Phillip 2011; 2012; Belford et al. 2019; Belford 2020).

EIA 3.3. The EIA’s statement, “the entire area is influenced by a mix of wave action, and sea waters carry a turbid sediment load for most of the year, hence inhibiting coral growth with its marine life (EIA 3.3)” is incorrectly stated since both Grande L’Anse and Salybia Reefs both experience similar high wave action and turbidity, yet illustrate unique growth for cnidarian species, such as Porites porites, Porites astreoides, Siderastrian radians, Favia fragum, Millepora alcicornis, Erythropodium sp., Plexaura sp., Gorgonia sp., Diplora clivosa, Zoanthus sp., Palythoa sp. Additionally, Grande L’Anse is unique in that it receives nutrients from cold water upwellings, thus extra nutrients highlight various species colour morphotypes visible in the area.

EIA 3.10.3-4 items mentioned in sections 3.10.3 and 3.10.4 are based on studies/reports done in 1988 (IMA 1988) and a Sea Bridge consultant team (Sea Bridge 1990), and as suggested data were collected on three (3) sites: Grand Riviere, Balandra Bay, and Toco Bay, thus reporting Toco Bay to be most adequate for the project. However, more indebt studies on species distribution and identification at Toco reefs were not available as they are now, hence you cannot base environmental decisions from data collected ~30 years ago!

EIA 4.3.1 statement, “…the waters surrounding the island are influenced by freshwater from the Amazon and Orinoco rivers. This discharge creates imperfect conditions for coral reef growth and habitat (Belford and Phillip 2011)” (4.3.1) is improperly cited. The proper citation is from Mallela and Harrod 2008, which states that freshwater causes seasonal fluctuations of salinity and turbidity. There is no mention of creating imperfect conditions due to freshwater discharge as a statement by Belford and Phillip (2011). In fact, most fringing reefs globally have freshwater output unto the reefs, yet these reefs survive, hence the statement made in this EIA suggesting imperfect growing conditions and loss of habitat for reefs is inaccurate. Also, please correct the author’s name if using any citation. Dr. Dawn Phillip was a respected lecturer at The University of the West Indies (St.

Augustine), and well-respected researcher of the Caribbean, hence correct spelling in a citation of the author’s name should be important.

EIA 4.3.1. Survey by ERM for three days in April 2019 and three days in September 2019 are not adequate enough to determine changes in benthic

communities. You need many years and at least 3-4 times annual measurements with replicates to have a robust dataset.

EIA 4.3.1.2. Drop cameras are ineffective at Grande L’Anse. Grande L’Anse is extremely turbid due to being an area of upwelling, and the narrow time window during which visibility was good enough (Belford et al. 2019)

EIA 4.3.2.2. There are other studies other than Belford and Phillip (2011), which provides more specific details on species distribution and biodiversity at Grande L’Anse and Salybia Bay Reefs. Please note that the study by Belford et al. 2019 highlights the Line and Point method using a 50-meter polyvinyl measuring tape with benthic records taken at 0.5-meter intervals, which provides a more detailed survey. Please review the following:

Belford SG. 2020. Spatial abundance and colour morphotype densities of the rock boring sea urchin (Echinometra lucunter) at two different habitats. Thalassas: An international Journal of Marine Sciences 36: 157-164.

Belford SG, Phillip DAT, Rutherford MG, Schmidt RS, Duncan EJ. 2019. Biodiversity of coral reef communities in marginal environments along the north- eastern coast of Trinidad, southern Caribbean. Progress in Aqua Farming and Marine Biology 2(1): 180017.

Belford SG, Phillip DAT. 2012. Intertidal distribution patterns of zoanthids compared to their scleractinian counterparts in the southern Caribbean.

International Journal of Oceanography and Marine Ecological System 1 3: 67-75.

Belford SG. 2007. Analysis of coral distribution and coral symbionts in a patch reef and fringing reef in the southern Caribbean. M.Sc. Thesis, Murfreesboro (TN): Middle Tennessee State University. 57 pages.

EIA 4.3.2.3. Study by Fanovich et al. 2011 used a 15 cm diameter PVC corer pushed to a depth of 25 cm, which essentially is a small area, yet the EIA states a low diversity of macroinvertebrates suggesting few species in the area. Once again, please review Belford et al. 2019 for a complete list of macroinvertebrates and cnidarians found for both Salybia and Grnade L’ Anse Reefs, which highlights 151 invertebrates.

EIA 4.3.2.5. Study by Buch 2017 does not include many organisms, such as Zoanthids (Palythoa and Zoanthus spp.), sea anemones (Stichodactyla, Epicustis/Phymanthus and Bunodosma spp.), Scleractinians (Diplora clivosa,

Porites asteroids, Siderastrea radians), Echinoderms (Echinometra, Eucidaris, Tripneustes, Ophioderma spp.), fishes (Chaetodon capistratus, Acanthurus chirurgus, Stegastes diencaeus, Abudefduf saxatilis, Amphichthys cryptocentrus) and many more (see Belford et al. 2019).

EIA 4.3.3. ERM EIA surveys for 2019 identified a mixture of sand, rock, and gravel at transect T6, which essentially is known to locals as Bravo Bay, and has all the aforementioned characteristics, however it is difficult to follow the statement, “when the quadrat data was average based on distance from the shore, bare sand and rock was still the highest average percent cover in the quadrats” as published data using line and point methods does not coincide with ERM EIA surveys in 2019. In fact, line and point survey done in June 2019 (unpublished data) recorded ~70 % hard and soft coral coverage with 13% coral rubble for Grande L’Anse. From observations, only the extreme end of Bravo Bay is sandy/rocky, and not Toco Bay, which is the area immediately to the right of the Toco Fishing Depot.

EIA 4.3.3.8. Although stated in your conclusions that Grande L’Anse is impacted by freshwater inputs from the Amazon and Orinoco Rivers and high intensity wave-action, this does not “create imperfect conditions” but fluctuations in salinity and turbidity, which is actually more affected by the rainy season in Trinidad. In general, tropical and sub-tropical coral reefs already grow in nutrient-poor ocean water, therefore your statement on ‘imperfect conditions’ is misleading.

Additionally, you cannot cite a reference (i.e. Belford and Phillip 2011) if a statement was not made in the article. Nowhere in the article did the authors say that ‘imperfect conditions’ limit coral growth and habitat, so please remove such incorrectly stated citations!

Why no marine benthic photographs??? Here are a few links to marine benthic photographs taken from 2005-2019

MMC Library: Martin Methodist College Marine Biology Collection https://artstor.blog/2016/09/26/case-study-going-underwater-with-shared-shelf- commons/

Digital Public Library of America https://dp.la/search?q=MARTIN+METHODIST+COLLEGE

EIA 5.3.4.3. The statement, “The benthic communities in Grande L’Anse Bay are likely comprised of mainly polychaetes, crustaceans, mollusks, and echinoderms,

similar to other Caribbean benthic communities, and therefore are quick to recover from disturbance (1-3 years) (Dernie et al. 2003; Manoukian et al. 2010)” misrepresents your cited source. Firstly, the paper by Dernie et al. (2003) only samples 10 cm diameter cores taken at 10 cm depths from sandy, clay, and muddy habitat located in the United Kingdom. You are comparing these smaller sample areas from a temperate location to the proposed tropical project area, which does not highlight recovery of coral reef disturbance anywhere in the article, hence an improper and irrelevant use of a cited reference! Dernie et al. (2003) highlights brief disturbances by researches, and not dredging disturbances for 18 months, as indicated by the Toco port project. Even worst, the document cites Manoukian et al. 2010, which looked at platform disturbances in the Adriatic Sea at distances of more than 70 meters from the shoreline. Please note that the Toco project is located at the shoreline.

The statement, “hard bottom benthic communities such as those in Grande L’Anse Bay will likely take between 10-20 years to recover” is not realistic and a generalized statement not supported by any source! Coral hard benthic communities in Jamaica hit by past hurricanes have not recovered some fifty years later.

The statement, “green sea turtles were observed by ERM to be present in Grande L’Anse Bay, likely feeding on algae on submerged hard structures (ERM Marine Baseline 2019). The removal of hard structure from the Project site will also remove these feeding habitats for sea turtles” is an important observation, since the marine green turtle is classified as endangered, hence the Project area should not be disturbed.

The statement, “all soft-bottom and hard-bottom benthic organisms within the Project area will be destroyed during dredging activities” and the impacts to the sea bed evaluated as “Large” is proof that all stakeholders should know that the reefs at Grande L’Anse will be 100% destroyed by the Toco port project. I am reminded that Newsday (Feb. 6, 2020) reported that Works and Transport Minister Rohan Sinanan said that construction of the Toco port would not significantly impact coral reefs on the north east coast. ERM’s reported statement said it will be destroyed! See the link below:

http://newsday.co.tt/2020/02/06/sinanan-toco-port-will-not-endanger-coral-reefs/

The statement, “the hard-bottom benthic communities, while not unique to Grande L’Anse Bay, are sensitive to disturbance and require a longer time period to

recolonize following disturbance (Connell et al. 1997)” once again is an incorrect citation of a resource, since this article mostly reports coral cover recovery percentages to be related to the type of disturbance. For example, short term coral recovery at 69%, and chronic disturbance resulting in 27% coral cover. This study surveyed the literature (65 studies) prior to 1997. Why not cite current studies?

If you have total loss of hard and soft bottom benthic communities (ERM Baseline 2019), then that’s a “Large” ecological sensitivity to dredging, not Medium as the statement suggests.

The statement, “the placement and installation of the breakwater, pilings, and fill material is considered a mitigation measure for hard-bottom benthic organisms and will serve as feeding habitats for sea turtles following recolonization” is a very generalized vague statement. The proposed area of the breakwater, pilings, etc. will not be in an adequate area to support or recolonize the biodiversity that will be lost from the destruction of the reefs at Grande L’Anse. If you snorkel the dock/jetty at the Toco Fishing Depot, or in Key Largo, Florida, or in Aqaba, Jordan, you will see sponges, algae, sea anemones growing on these structures, NOT a coral reef!

The statement, “an additional mitigation measure for the dredging impacts on the hard bottom marine communities is the installation of artificial reefs at locations to-be-decided” is not feasible since there is no experience in setting up artificial reefs in Trinidad and Tobago, neither designing, managing or monitoring artificial reefs in Trinidad and Tobago. Additionally, the statement “to-be-decided” may also mean that the decision on not to add an artificial reef will be made.

EIA 6.2.7.5. The statement recommends a hard structure long-term monitoring program establishing a professor and students from either UTT, UWI, or USC. Please note that long-term monitoring has been consistently done annually since 2005 by former and current professors of UWI and Martin Methodist College (MMC), however with the proposed 100% destruction of marine benthos at the project site, don’t think you will require the aforementioned services.

EIA 6.2.7.6. Artificial reef monitoring is not feasible in this case as there is a lack of experience in artificial reef design, development, and monitoring in this region. Since the EIA report does not highlight a proposed design of an artificial reef, by definition it is not an artificial reef, as the project destroys an already existing natural reef, and a man-made structure/object promoting marine life, such as construction debris, or scuttling a ship purposely to encourage marine life is not the case here. A long-term grant or contract to monitor the proposed artificial reefs is

irrelevant, since actual long-term monitoring of “live” reefs by professors and students since 2005-present were totally voluntary, or paid by participants, and by small financial gifts or grants obtained by the respective institutions (UWI and MMC).

EIA 7. Table 7.1. Impact summary for seabed dredging is confusing. Since there will be total destruction of soft and hard-bottom marine benthic communities (as stated by ERM 2019, how can the impact before and after mitigation be “Moderate”? The same goes for Marine Ecology-Vessel Traffic/Vessel Releases.

References

Belford SG, Phillip DAT. 2012. Intertidal distribution patterns of zoanthids compared to their scleractinian counterparts in the southern Caribbean.

International Journal of Oceanography and Marine Ecological System 1 3: 67-75.

Belford S, Phillip D. 2011. Rapid assessment of a coral reef community in a marginal habitat in the southern Caribbean: a simple way to know what’s out there. Asian Journal of Biological Sciences 4(7): 520-531.

Online Marine Biology Resources

MMC Library: Martin Methodist College Marine Biology Collection https://artstor.blog/2016/09/26/case-study-going-underwater-with-shared-shelf- commons/

Digital Public Library of America https://dp.la/search?q=MARTIN+METHODIST+COLLEGE